BILL ANALYSIS                                                                                                                                                                                                    Ó



                                                                  AB 975
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          ASSEMBLY THIRD READING
          AB 975 (Wieckowski and Bonta)
          As Amended May 24, 2013
          Majority vote 

           HEALTH              12-7        APPROPRIATIONS            11-5  
           
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          |Ayes:|Pan, Ammiano, Atkins,     |Ayes:|Gatto, Bocanegra,         |
          |     |Bonilla, Bonta, Gomez,    |     |Bradford,                 |
          |     |Roger Hernández, Gordon,  |     |Ian Calderon, Campos,     |
          |     |Mitchell, Nazarian,       |     |Eggman, Gomez, Ammiano,   |
          |     |V. Manuel Pérez,          |     |Pan, Quirk, Weber         |
          |     |Wieckowski                |     |                          |
          |     |                          |     |                          |
          |-----+--------------------------+-----+--------------------------|
          |Nays:|Logue, Chesbro,           |Nays:|Harkey, Bigelow,          |
          |     |Maienschein, Mansoor,     |     |Donnelly, Linder, Wagner  |
          |     |Nestande, Wagner, Wilk    |     |                          |
          |     |                          |     |                          |
           ----------------------------------------------------------------- 
           SUMMARY  :  Revises California's nonprofit community benefits  
          requirements to include multispecialty clinics and narrows the  
          activities that constitute community benefits, creates a  
          definition of charity care, requires the Office of Statewide  
          Health Planning and Development (OSHPD) to develop a  
          standardized methodology for calculating community benefits,  
          calculate the value of community benefits for submitting  
          entities, and to issue civil penalties for noncompliance with  
          filing requirements.  Specifically,  this bill  :  

          1)Requires private nonprofit hospitals and nonprofit  
            multispecialty clinics to provide community benefits to the  
            community.  Requires, by January 1, 2016, these entities to  
            develop, in collaboration with the community, a community  
            benefits statement (that describes the hospital or clinic's  
            commitment to developing, adopting, and implementing a  
            community benefits program), a community needs assessment  
            (that evaluates the health needs and resources of the  
            community it serves).  Requires by April 1, 2016, the  
            development of a community benefits plan to achieve specified  
            outcomes.  Requires the community health needs assessment to  
            be made available to the public for review and comment prior  
            to approval.  Requires the assessment to be filed with OSHPD  








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            and updated at least every three years.  Requires OSHPD to  
            make these documents available on its Internet Web site.

          2)Establishes specifications for the community benefits plan  
            such as a list of services categorized by charity care; other  
            community benefits, such as health professions education,  
            subsidized health services, school based health centers,  
            research and contributions to community groups; community  
            building activities targeting underserved and vulnerable  
            populations; an estimate of the economic value of the  
            community benefits that the private nonprofit hospital or  
            nonprofit multispecialty clinic intends to provide; a  
            description of the intended impact on health outcomes  
            attributable to the plan, including short- and long-term  
            measurable goals and objectives; the name and title of the  
            individual responsible for implementing the plan; and, the  
            names of individuals on the private nonprofit hospital's or  
            nonprofit multispecialty clinic's governing board.

          3)Establishes a definition for what qualifies as charity care to  
            mean the unreimbursed cost to a private nonprofit hospital or  
            nonprofit multispecialty clinic of providing services to the  
            uninsured, or underinsured, as well as providing funding or  
            otherwise financially supporting any of the following:
             a)   Health care services or items on an inpatient or  
               outpatient basis to a financially qualified patient with no  
               expectation of payment;

             b)   Health care services or items provided to a financially  
               qualified patient through other nonprofit or public  
               outpatient clinics, hospitals, or health care organizations  
               with no expectation of payment; and,

             c)   Community benefits, provided that the provision,  
               funding, or financial support of those benefits is  
               demonstrated to reduce community health care costs.

          4)Clarifies existing law to specify that charity care does not  
            include uncollected fees or accounts written off as bad debt;  
            care provided to patients for which public or private grant  
            funds pay for any of the charges for the care; contractual  
            adjustments in the provision of health care services below the  
            amount identified as gross charges by the health care   
            provider; any amount over 125% of the Medicare rate for the  








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            health care services or items provided on an inpatient or  
            outpatient basis, any amount over 125% of the Medicare rate  
            for providing funding for health care services or items with  
            no expectation of payment provided to financially qualified  
            patients through other nonprofit or public outpatient clinics,  
            hospitals or health care organizations; or, the cost to a  
            nonprofit hospital of paying a tax or other governmental  
            assessment.

          5)Applies this bill's provisions to private nonprofit acute care  
            hospitals operated or controlled by a nonprofit corporation,  
            as defined, that has been determined exempt from taxation  
            under the United States Internal Revenue Code (IRC), and  
            nonprofit multispecialty clinics, defined in existing law as  
            clinics operated by a nonprofit corporation exempt from  
            federal income taxation, as specified, under Section 501 of  
            the IRC that conduct medical research and health education and  
            provide health care to its patients through a group of 40 or  
            more physicians and surgeons, who are independent contractors  
            representing not less than 10 board-certified specialties, and  
            not less than two-thirds of whom practice on a full-time basis  
            at the clinic.  Exempts district hospitals, children's  
            hospitals, and rural general acute care hospitals.

          6)Requires OSHPD to calculate and make public the total value of  
            community benefits provided by private nonprofit hospitals and  
            nonprofit multispecialty clinics that bi-annually report  
            pursuant to this bill.

          7)Authorizes OSHPD to assess a civil penalty against any private  
            nonprofit hospitals or nonprofit multispecialty clinic that  
            fails to comply with this bill in the amount of $100 a day for  
            delays in filing and not more than $5,000 for not using  
            approved accounting systems.

          8)Updates Cal-Mortgage requirements to include the community  
            assessment required by this bill as an activity an applicant  
            must demonstrate participation in, if appropriate.

           FISCAL EFFECT  :  According to the Assembly Appropriations  
          Committee, initial costs to OSHPD (California Health Data and  
          Planning Fund) of approximately $2.2 million, with ongoing costs  
          after that of approximately $450,000 annually.  Costs include  
          information technology staff for various data functions and  








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          accounting and reporting services staff to ensure compliance  
          with reporting, audit complex documents, develop regulations,  
          monitor overall compliance and assess penalties.

           COMMENTS  :  According to the author, this bill will create a  
          standard definition of charity care that includes a refined  
          definition of community benefits for nonprofit hospitals.   
          Further, this bill will clearly define what constitutes charity  
          care, which must be a direct provision of care, not promotional  
          activities or cost containment, as currently provided within the  
          guidelines of "community benefit," and will improve reporting  
          requirements for greater public transparency in how hospitals  
          meet their charity care obligation, with rigorous financial  
          penalties for hospitals that fail to meet reporting  
          requirements. 

          In a report prepared by the Senate Office of Research (SOR) for  
          an August 15, 2012, hearing of the Senate Select Committee on  
          Charity Care and Nonprofit Hospitals, about 247 of California's  
          387 private hospitals may be eligible for certain tax exemptions  
          due to their nonprofit status in exchange for providing various  
          community benefits, such as charity care.  However, these  
          community benefits are not uniformly defined or measured.  This  
          ambiguity makes it challenging to hold hospitals accountable for  
          the special tax benefits they receive and determine if they are  
          providing meaningful community benefits.  Furthermore, some  
          studies show many investor-owned hospitals and public hospitals  
          provide charity care and other community benefits similar to or  
          greater than their nonprofit counter parts.  

          According to SOR, the federal Patient Protection and Affordable  
          Care Act (ACA) generally mirrors much of California's existing  
          state requirements for nonprofit hospitals.  The ACA also  
          includes new reporting requirements.  Nonprofit hospitals are  
          required to report to the Internal Revenue Service (IRS) the  
          results of the community needs assessment and if all identified  
          needs are not addressed, they are required to provide the  
          reasons why.  Hospitals also must submit audited financial  
          statements to the IRS.  These reporting requirements are in  
          addition to the preexisting requirements of Form 990 and  
          schedule H.  Failure to comply makes hospitals subject to an  
          excise tax penalty of $50,000 and the loss of their federal tax  
          exemption.









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          The California Nurses Association (CNA) writes in support of  
          this bill that it seeks to define charity care for nonprofit  
          hospitals and refine what is considered "community benefits" to  
          ensure California's nonprofit hospitals are fulfilling their  
          mission statements and providing community benefits in exchange  
          for their tax-exempt status.  CNA adds that in 2010, more than  
          seven million Californians lacked health insurance and that even  
          with so many in need of health care, California's nonprofit  
          hospitals benefited $1.8 billion from their tax-exempt status.   
          According to CNA for the most recent year data are available,  
          half of California's nonprofit hospitals provided 2.46% or less  
          of their operating costs on charity, well below the federal  
          standard of 5% needed to maintain tax exempt status.  Nonprofit  
          hospitals accumulated $4.5 billion in profits that same year,  
          close to half of that by two of California's largest hospital  
          chains Sutter Health and Kaiser Permanente.  Health Access  
          California (HAC), Consumer Federation of California, and  
          Consumer Watchdog all write in support of the definitions in  
          this bill for what constitutes charity care and community  
          benefits.  HAC argues that hospitals use the term "uncompensated  
          care," which means bad debt where collection agencies, some  
          owned by nonprofit hospital systems, pursue the uninsured to the  
          point of bankruptcy and seizure of their homes; therefore,  
          defining charity care as care for which there is no expectation  
          of payment, hospitals would no longer be able to claim bad debt  
          as charity care.

          The California Hospital Association opposes this bill in part  
          based on the re-write of community benefits law, indicating,  
          instead of the current system where communities collaborate with  
          non- profit hospitals to tailor a realistic community benefit  
          plan, this bill now says that hospitals must address every  
          identified need, regardless of cost and demonstrate that they  
          are achieving measurable results.  Kaiser Permanente writes in  
          opposition, stating the very narrow definition of community  
          benefit in this bill could exclude critically important programs  
          for low-income, uninsured, and indigent Californians.  The  
          California Chamber of Commerce writes businesses are becoming  
          increasingly aware that improving the health of their  
          communities at large is good for everyone.  Community-based  
          organizations play a critical role in improving the health of  
          the community through prevention initiatives that make  
          health-promoting changes in the places where people live, learn,  
          work and play.  By revising the definition of charity care, this  








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          bill will result in reduced funding for those community-based  
          organizations and jeopardize community based prevention efforts.


           Analysis Prepared by  :    Lara Flynn / HEALTH / (916) 319-2097 


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